CDM project activity/programme of activities registration request review form (CDM-REGR-FORM) (Version 03.0)

Reference number of the proposed CDM project activity/programme of activities (PoA) submitted for registration	9613
Title of the proposed CDM project activity/PoA submitted for registration	Power Generation using Waste pressure Energy of BF gas from Gas Expansion Turbine Station of BF-3 of Rashtriya Ispat Nigam Limited
Please indicate, in accordance with paragraphs 37 and 40 of the CDM modalities and procedures, which validation requirement(s) may require review. A list of requirements is provided below. Please provide reasons in support of the request for review. Including any supporting documentation.
The following are requirements derived from paragraph 37 of the CDM modalities and procedures:
The participation requirements as set out in paragraph 28 to 30 of the CDM modalities and procedures are satisfied; Comments by local stakeholders have been invited, a summary of the comments received has been provided, and a report to the designated operational entity (DOE) on how due account was taken of any comments has been received; Project Participants have submitted to the DOE documentation on the analysis of the environmental impacts of the project activity, including transboundary impacts and, if those impacts are considered significant by the project participants or the host Party, have undertaken an environmental impact assessment in accordance with procedures as required by the host Party; The project activity is expected to result in a reduction in anthropogenic emissions by sources of greenhouse gases that are additional to any that would occur in the absence of the proposed project activity, in accordance with paragraphs 43 to 52 of the CDM modalities and procedures; The baseline and monitoring methodologies comply with requirements pertaining to methodologies previously approved by the Executive Board; Provisions for monitoring, verification and reporting are in accordance with decision 17/CP.7, the CDM modalities and procedures and relevant decisions of the COP/MOP; The project activity conforms to all other requirements for CDM project activities in decision 17/CP.7, the CDM modalities and procedures and relevant decisions by the COP/MOP and the Executive Board.
The following are requirements derived from paragraph 40 of the CDM modalities and procedures:
The DOE shall, prior to the submission of the validation report to the Executive Board, have received from the project participants written approval of voluntary participation from the designated national authority of each Party involved, including confirmation by the host Party that the project activity assists it in achieving sustainable development; In accordance with provisions on confidentiality contained in paragraph 27(h) of the CDM modalities and procedures, the DOE shall make publicly available the project design document; The DOE shall receive, within 30 days, comments on the validation requirements from Parties, stakeholders and UNFCCC accredited non-governmental organizations and make them publicly available; After the deadline for receipt of comments, the DOE shall make a determination as to whether, on the basis of the information provided and taking into account the comments received, the project activity should be validated; The DOE shall inform project participants of its determination on the validation of the project activity. Notification to the project participants will include confirmation of validation and the date of submission of the validation report to the Executive Board; The DOE shall submit to the Executive Board, if it determines the proposed project activity to be valid, a request for registration in the form of a validation report including of the project design document, the written approval of the host Party and an explanation of how it has taken due account of comments received.
There are only minor issues which should be addressed by the DOE/project participants prior to the registration of the project.
Additional information
1) 1.The DOE is requested to clarify how the input parameter “ Escalation in O&M cost” is applicable at the time of investment decision since the value for this parameter is sourced from CERC Tariff Order dated January 2009 whereas the investment decision is in May 2006. 2.The DOE shall also clarify why the savings from the avoided Contract Maximum Demand (CMD) charges due to the operation of 14MW project activity is not taken into account in the IRR calculation. In doing so, the DOE shall validate the impact on IRR after inclusion of CMD charges. Please refer to para 6 of EB 62 Annex 5, VVS version 05 Para 120 (d). 2) 3.The DOE/PP is requested to state the different power source to meet the increased demand (102 MW) of the facility after the project implementation. In doing so please provide the installed power generation capacity from each fuel source: existing coal based CPP, greenfield coal based CPP (please state if already commissioned, and when), grid power import and the 14 MW under the Project activity . 4.The DOE is requested to clarify how it validated that grid is the the most plausible and credible baseline scenario given the fact that : i)The baseline alternatives do not have comparable level of service/outputs in terms of power generation (for instance Option P7 and P9 refers to alternative scenarios for 14 MW , Option P8 (greenfield fossil fuel plant) refers to alternative for 119MW, Option P10 (grid) refers to 35 MW). ii) The DOE is also requested to provide the investment comparison analysis from all the credible alternatives to meet the increased power demand after capacity expansion of the facility as required by Step 2 Option 2 of Baseline Determination section of the applied methodology ACM0012 ver 4. iii)The DOE is required to validate whether all possible baseline alternatives have been included such as,(a) installation of a Greenfield 100 MW Coal based Captive Power Plant (b) installation of l turbine of 32 MW capacity in addition to the 67.5MW turbine in the greenfield coal based captive power plant which will cater to the increased power demand . iv) The DOE is requested to clarify the different power generation based on waste gas/heat/pressure that is existing in the facility of RINL, in particular, the DOE is requested to clarify how it validated Options P7 and P9 of the PDD and correct the inconsistencies between them. Please refer to VVS version 05 para 89-93; Step 2- Option 2 of ACM0012 ver 4. 3). The DOE is requested to clarify how it can confirm that "1. All assumptions and data used by the project participants are listed in the PDD, including their references and sources; 2. All documentation used by project participants as the basis for assumptions and source of data is correctly quoted and interpreted in the PDD; 3. All values used in the PDD are considered reasonable in the context of the proposed project activity; 4. The baseline methodology and corresponding tool(s) have been applied correctly to calculate project emissions, baseline emissions, leakage and emission reductions; 5. All estimates of the baseline emissions can be replicated using the data and parameter values provided in the PDD." given the PDD does not have a list of sources / documents used. 4). The DOE is requested to provide a validation report with proper and complete list of sources (including consistent provision of dates) and ensure that all statements in the text can be verified (e.g. p.28: April 2008: no source for Process for Appointment of Consultant; p.29: no source for 13/10/2010 Appointment of consultant Copy of letter to the CDM consultant for appointment for CDM consultancy). In addition, the DOE is requested to ensure proper references within the whole validation report. e.g. no transparent sources are given in VR which the DOE used to validate the information provided by the PP in the PDD with regards, e.g. - Power Tariff escalation rate (VR, p.38), - Income tax depreciation (VR, p.39). 5). Input values: The DOE is requested to elaborate on and provide a complete list of taxes checked, including a comprehensive list of references that let Bureau Veritas Certification conclude: "Bureau Veritas Certification has also verified values of various taxes through crosschecking with the taxation rules (footnote 13) conducted by local government and found to be fully consistent." 6): IRR/sensitivity analysis: a) The DOE is requested to provide a detailed, updated IRR calculation sheet with detailed references (incl. pages of the quoted sources) and explain the tax rate value of 33.66 % and MAT of 11.22% including provision of complete, detailed and correct sources beyond http://indiabudget.nic.in/ub2006-07/bh/bh1.pdf. b). The DOE is requested to substantiate the projects costs and how it checked the appropriateness of the assumptions and values. How did the DOE check the actual cost incurred by the PP of INR 800.00 million (VR, p.41, no source, but same value as FSR statement) allowing the conclusion that a low cost scenario is not realistic.
Date	26 Mar 14